MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and a penalty under section 6662 as follows:
Penalty Year Deficiency Sec. 6662 1993 ................. $130,822 $26,164 1994 ................. 135,336 27,067 1995 ................. 120,550 24,110
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